Elementary and Secondary Education Act:

Potential Effects of Changing Comparability Requirements

GAO-11-258: Published: Jan 28, 2011. Publicly Released: Feb 28, 2011.

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For fiscal year 2010, Congress appropriated $14.5 billion for Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA), which funds services to students in schools with high concentrations of students from low-income families. Title I, Part A includes several fiscal requirements, which are designed to prevent local school districts from using federal dollars to replace state and local education funding. One of these measures, Title I comparability, requires districts to provide services with state and local funds to Title I schools that are at least comparable to services provided in schools not served by Title I. State educational agencies monitor district compliance with Title I comparability requirements. Districts may comply with comparability requirements through one of several measures. Under Title I, districts are deemed to be in compliance with comparability requirements if they have established and implemented a districtwide salary schedule; a policy to ensure equivalence among schools in teachers, administrators, and other staff; and a policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies. Guidance from the U.S. Department of Education (Education) also allows districts to comply with requirements through several other measures, including student-teacher ratios (referred to in guidance as student-to-instructional-staff ratios) and expenditures per pupil. Under Title I, districts are precluded from including staff salary differentials for years of employment in determining comparability. Thus, actual teacher salaries may not be used in comparability calculations. An Education analysis of a nationally representative sample of school districts did not find a significant difference between Title I and non-Title I schools in state and local expenditures on personnel for the 2004-2005 school year. However, this study did not attempt to evaluate whether expenditures at Title I and non-Title I schools within the same district were different. Some other research shows that teachers at Title I schools in some districts have fewer years of experience and lower average salaries than teachers at non-Title I schools in the same district. As a result, Title I schools in these districts may receive less state and local funding per pupil than non-Title I schools. A bill was introduced in the prior session of Congress to require districts to demonstrate comparability using an expenditure-per-pupil measure that includes actual teacher salaries.4 Advocates believe that this kind of requirement would help eliminate any funding discrepancies between Title I and non-Title I schools due to lower teacher salaries at Title I schools and improve educational outcomes at Title I schools. This report addresses the following questions: (1) Which of the methods for demonstrating comparability are used by school districts in selected states and how does the chosen method affect resource allocation in selected school districts? (2) What have been Education's monitoring and audit findings for comparability? (3) What might be the benefits and drawbacks of requiring school districts to use an expenditure-per-student ratio that includes actual teacher salaries to demonstrate compliance with comparability requirements?

We found that: 1) Districts in selected states commonly demonstrate comparability using student-teacher ratios, but factors other than comparability may drive their resource-allocation decisions; 2) Education has found weaknesses in state oversight of district compliance with comparability requirements; and 3) Potential changes in comparability requirements could increase funding to some Title I schools, but may be challenging for some districts to implement. Some district and union officials we interviewed supported providing additional funds to Title I schools, but some also noted potential challenges and budgetary implications of complying with revised requirements, including transferring teachers and negotiating changes to union contracts. For example, Oakland Unified School District currently distributes state and local funds to schools to ensure comparable per-pupil funding, but some schools have had difficulty balancing their budgets.

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